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examination.
The fraudulent and corrupt activity of Mr. Duncan and
petitioner’s accountant during respondent’s examination of
petitioner included causing an employee of petitioner to prepare
77 false deposit slips incorrectly identifying amounts totaling
$179,579.36 that were deposited into one of petitioner’s bank
accounts (petitioner’s 1991 deposits) as loans from Mr. Duncan to
petitioner. By presenting such false receipts to respondent’s
examining agents, Mr. Duncan intended to mislead respondent’s
examining agents into believing that certain of petitioner’s
receipts during taxable year 1991 constituted the repayment by
Mr. Duncan of loans made to him by petitioner, rather than income
to petitioner. Furthermore, when initially asked about the
source of petitioner’s 1991 deposits, Mr. Duncan told respon-
dent’s revenue agents on behalf of petitioner that those deposits
had to have been made from his personal account. The fraudulent
and corrupt activity of Mr. Duncan and petitioner’s accountant
during respondent’s examination of petitioner also included
directing an employee of petitioner to create a fictitious
receipt in the amount of $9,610 for petitioner’s taxable year
1990 to document the alleged purchase of an oriental rug from
Georgio Armani, which was then presented to respondent’s examin-
ing agents. In fact, as we found above, the $9,610 that peti-
tioner paid Georgio Armani during 1990 was for the purchase of
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